9 replies to this topic

[QAKat]

Hello, 

 

We have a new supplier that claims "Vanilla Extract" as the ingredient they are supplying. I put it in quotations because per FDA I do not think it is Vanilla Extract. The customer changed the vanilla we were previously using because they want the ingredient statement to say vanilla extract or vanilla flavor which I think flavor is correct.

 

Also, if they supplier is claiming vanilla extract and it is not would it also be food fraud?

 

The ingredients are as follow: Sugar, water, vanilla flavor, natural vanilla flavor, xanthan gum and caramel color. 

 

Per FDA: 

 

 

Sec. 169.175 Vanilla extract.

(a) Vanilla extract is the solution in aqueous ethyl alcohol of the sapid and odorous principles extractable from vanilla beans. In vanilla extract the content of ethyl alcohol is not less than 35 percent by volume and the content of vanilla constituent, as defined in § 169.3©, is not less than one unit per gallon. The vanilla constituent may be extracted directly from vanilla beans or it may be added in the form of concentrated vanilla extract or concentrated vanilla flavoring or vanilla flavoring concentrated to the semisolid form called vanilla oleo-resin. Vanilla extract may contain one or more of the following optional ingredients:

(1) Glycerin.

(2) Propylene glycol.

(3) Sugar (including invert sugar).

(4) Dextrose.

(5) Corn sirup (including dried corn sirup).

(b)(1) The specified name of the food is "Vanilla extract" or "Extract of vanilla".

(2) When the vanilla extract is made in whole or in part by dilution of vanilla oleoresin, concentrated vanilla extract, or concentrated vanilla flavoring, the label shall bear the statement "Made from ______" or "Made in part from ______", the blank being filled in with the name or names "vanilla oleoresin", "concentrated vanilla extract", or "concentrated vanilla flavoring", as appropriate. If the article contains two or more units of vanilla constituent, the name of the food shall include the designation "__-fold", the blank being filled in with the whole number (disregarding fractions) expressing the number of units of vanilla constituent per gallon of the article.

(3) Wherever the name of the food appears on the label so conspicuously as to be easily seen under customary conditions of purchase, the labeling required by paragraph (b)(2) of this section shall immediately and conspicuously precede or follow such name, without intervening written, printed, or graphic matter.

© Label declaration. Each of the ingredients used in the food shall be declared on the label as required by the applicable sections of parts 101 and 130 of this chapter.

[42 FR 14479, Mar. 15, 1977, as amended at 58 FR 2886, Jan. 6, 1993]

 

[SQFconsultant]

Based on this ..

The ingredients are as follow: Sugar, water, vanilla flavor, natural vanilla flavor, xanthan gum and caramel color.

I don't think it is extract - flavoring sure but even that it sounds pretty base considering having to color it with the carcinogenic caramel coloring.

Having dealt with several MADAGASCAR harvesters and processors they would tell you it sounds like food fraud for economic gain.

Edited by SQFconsultant, 27 April 2023 - 02:21 AM.

[QAKat]

Based on this ..

The ingredients are as follow: Sugar, water, vanilla flavor, natural vanilla flavor, xanthan gum and caramel color.

I don't think it is extract - flavoring sure but even that it sounds pretty base considering having to color it with the carcinogenic caramel coloring.

Having dealt with several MADAGASCAR harvesters and processors they would tell you it sounds like food fraud for economic gain.

Hi SQF Consultant, 

 

Those were my thoughts exactly. When we received the spec sheet for the ingredient it said vanilla paste and the nutritionals were also off compared to the actual product label. I just want to be sure so I can cover my companies back and also want to know how to go about it with the supplier. It's tough without knowing all the regulations. I didn't even know caramel color was a carcinogen and part of the 4-MEI. 

 

Thank you for your input. Very much appreciated 

[kingstudruler1]

Based on this ..

The ingredients are as follow: Sugar, water, vanilla flavor, natural vanilla flavor, xanthan gum and caramel color.

I don't think it is extract - flavoring sure but even that it sounds pretty base considering having to color it with the carcinogenic caramel coloring.

Having dealt with several MADAGASCAR harvesters and processors they would tell you it sounds like food fraud for economic gain.

 

I made vanilla extract for 10 + years.  I agree, Its not extract.   At a best, it is vanilla paste with other natural flavors.   Worst case, its all imitation.  

[QAKat]

I made vanilla extract for 10 + years.  I agree, Its not extract.   At a best, it is vanilla paste with other natural flavors.   Worst case, its all imitation.  

Hi Kingstudruler1,

 

When they sent us the spec sheet it was stated as vanilla paste!!! In the actual bottles it states "Vanilla Extract" so we asked them why the names were different and they said it was a printing error. Even their nutritional information was incorrect. I just want to know how to change it on the label to what the correct term would be. We were using an actual flavor so on the label I have it as natural flavor. 

 

Thank you so much!! I've been stressing about this.

[Scotty_SQF]

I wouldn't be using products from that supplier if this is the situation you encountered and they would be disqualified as a supplier.

[QAKat]

I wouldn't be using products from that supplier if this is the situation you encountered and they would be disqualified as a supplier.

 

Hi Scotty, 

 

This is the supplier and the vanilla the customer is asking for. I talked to someone from the vanilla company this morning and he said both them and customer came to the agreement that they were going to call it extract and that this specific ingredient is custom made for them. The customer is not SQF they're a retail store that sells to you and I. I will just communicate to the supplier that from our end we will be calling the vanilla exactly what it is and will be changing the ingredient statement on the label to what the vanilla is. 

[kingstudruler1]

Hi Kingstudruler1,

 

When they sent us the spec sheet it was stated as vanilla paste!!! In the actual bottles it states "Vanilla Extract" so we asked them why the names were different and they said it was a printing error. Even their nutritional information was incorrect. I just want to know how to change it on the label to what the correct term would be. We were using an actual flavor so on the label I have it as natural flavor. 

 

Thank you so much!! I've been stressing about this.

 

I think i get it.   

 

You / your customer wanted extract.   supplier sent you extract, but gave you spec sheet and paper work for paste correct?  

 

If it is indeed extract (from your definition above), you could label it as natural flavor in your ingredient statement..  this isn't very common as vanilla extract "looks" better on a label than "natural flavor"   

 

 

101.22

The term natural flavor or natural flavoring means the essential oil, oleoresin, essence or extractive, protein hydrolysate, distillate, or any product of roasting, heating or enzymolysis, which contains the flavoring constituents derived from a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf or similar plant material, meat, seafood, poultry, eggs, dairy products, or fermentation products thereof, whose significant function in food is flavoring rather than nutritional. Natural flavors include the natural essence or extractives obtained from plants listed in §§ 182.10, 182.20, 182.40, and 182.50 and part 184 of this chapter, and the substances listed in § 172.510 of this chapter.

[QAKat]

I think i get it.   

 

You / your customer wanted extract.   supplier sent you extract, but gave you spec sheet and paper work for paste correct?  

 

If it is indeed extract (from your definition above), you could label it as natural flavor in your ingredient statement..  this isn't very common as vanilla extract "looks" better on a label than "natural flavor"   

 

 

101.22

The term natural flavor or natural flavoring means the essential oil, oleoresin, essence or extractive, protein hydrolysate, distillate, or any product of roasting, heating or enzymolysis, which contains the flavoring constituents derived from a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf or similar plant material, meat, seafood, poultry, eggs, dairy products, or fermentation products thereof, whose significant function in food is flavoring rather than nutritional. Natural flavors include the natural essence or extractives obtained from plants listed in §§ 182.10, 182.20, 182.40, and 182.50 and part 184 of this chapter, and the substances listed in § 172.510 of this chapter.

No. The ingredient is not extract. What the spec sheet says is what is in the product (The ingredients are as follow: Sugar, water, vanilla flavor, natural vanilla flavor, xanthan gum and caramel color) which are not ingredients of extract as you had mentioned before. 

 

The bottle says brand name, Vanilla Extract, that its made in Mexico and ingredient statement which are the ingredients I mentioned above. 

 

The person I spoke to yesterday that works with the manufacturer even told me that they are using non natural ingredients in the product but couldn't tell me which ones. I think they are doing monkey business. 

[Scotty_SQF]

Hi Scotty, 

 

This is the supplier and the vanilla the customer is asking for. I talked to someone from the vanilla company this morning and he said both them and customer came to the agreement that they were going to call it extract and that this specific ingredient is custom made for them. The customer is not SQF they're a retail store that sells to you and I. I will just communicate to the supplier that from our end we will be calling the vanilla exactly what it is and will be changing the ingredient statement on the label to what the vanilla is. 

Understandable.  Thanks for clearing that up.   Your customer is ok with this risk and then them possibly risking your certification for selecting this?  I agree with you, I'd call it what it is, but it seems you are doing a lot of work for your customer to make sure your facility maintains compliance.  The customer should be grateful for that and maybe you should upcharge them a little bit.  The customer isn't making it easy on you huh?